May 22, 2015

Exemption No. 11684

Regulatory Docket No. FAA–2015–0694

Mr. Raffael Aieta

Mr. Dylan Ohman

Aerial Photography and Survey LLC

435 East 53rd Avenue

Eugene, OR 97405

Dear Messrs. Aieta and Ohman:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 16, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Aerial Photography and Survey LLC (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct operations for the agriculture, aerial photography, construction, inspection, 

surveying, and wildlife preservation industries.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a 3D Robotics Iris+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 
2

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Aerial Photography and Survey LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

Conditions and Limitations

In this grant of exemption, Aerial Photography and Survey LLC is hereafter referred to as 

the operator.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the 3D Robotics Iris+

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
4

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Aerial Photography and Survey lie. 

Raffael Aieta 

Dylan Ohman 

435 E. 53rd Ave. 

Eugene OR 97405 

541-525-3917 

apsUAVs@gmail.com 

March 16, 2015 

U.S. Department of Transportation 

Docket Operations 

1200 New Jersey Ave., SE 

Washington, DC 20590 

]fijf d.:.J 

Re: Submission of Request for Authorization to Conduct Unmanned Aircraft Systems 

Operations Allowed by Section 333 of the FAA Modernization and Reform Act of 2012 

Through the Exemption Process Identified Under 14 C.F.R. Section 11.81 

Dear Sir/Madam, 

Pursuant to Section 333 of PL I 12-95 commonly known as the "FAA Modernization and 

Reform Act of2012" or "The Reform Act", Aerial Photography and Survey llc.(d/b/a APS ), hereby 

applies for authorization to conduct commercial unmanned aerial systems (UAS) operations for the 

agriculture, aerial photography, construction, inspection, surveying, and wildlife preservation 

industries, within the airspace of the state of Oregon; within Class G and occasionally E airspace, 

along with additional restrictions identified herein. 

Contained within is detailed information on why the approval of this request is in the 

" ... pub I ic' s interest ... " and how the approva I wi II " ... provide a level of safety at least equal to that 

provided by the rule ... " APS, seeks exemption from. APS looks forward to working closely with the 

FAA to" ... safely accelerate the integration of civil unmanned aircraft systems into the national 

airspace system ... " as directed by Congress. 

Thank you for your time and consideration in this matter and please feel free to contact us 

with additional information or requests. 

/J 

~~J / . 

crr- ·r r~ Raffael Aieta 

Owner I Operator 

APS 

Applicant contact information: 

~~~> Dylan Ohman 

Owner/Operator 

APS 
~- _; 

Raffael Aieta 

435 E 53rd Ave. 

Eugene OR 97405 

541-525-3917 

apsUA Vs@gmail.com 

Table of Contents 

I. Company Background 

II. Training & Operations 

II I. Regulations- Exemptions Requested 

a. 14 C.F.R. Part 21 Subpart H- Airworthiness Certificates 

b. 14 C.F.R. § 45.23(b)- Aircraft Marking and Identification R~quirements 

c. 14 C.F.R. § 61.113 (a)& (b) and§ 61.133(a)(l)- Private and Commercial Pilot Privilege 

and Limitations 

d. 14 C.F.R. § 91. 7(a)- Civil Aircraft Airworthiness 

e. 14 C.F.R. § 91.103- Preflight Action 

f. 14 C.F.R. § 91.109- Flight Instruction 

g. 14 C.F.R. § 91.119- Minimum Safe Altitudes 

h. 14 C.F.R. § 91.121 -Altimeter Settings 

i. 14 C.F.R. § 91.151 (a)- Fuel Requirements for Flight in VFR Conditions 

j. 14 C.F.R. § 91.405(a), § 91.407(a)(l), § 91.409(a)(2) and§ 91.417(a) & (b)- Maintenance 

Inspections 

IV. Public Interest 

V. Privacy Concerns 

VI. FAA Collaboration 

Summary -Federal Register 
·~ 

----------

I. Company 

APS, was founded in 2015 by two friends in a joint effort to create unique business opportunities by 

utilizing the new sUAS technology. Both partners have a lifelong love of anything that flies and strong 

backgrounds flying high performance R/C aircraft. This fact mixed with the real world experience of 

filming and editing action sports such as snowboarding and motocross led the partners to the conclusion 

that starting a company in the sUAS market could combine our available skills to provide us the 

opportunity to build a business that would not only be viable but would also provide us a chance to do 

what we love. APS owner/operator Raffael Aieta also attended Lane Community College flight school for 

two years and logged ~140 hours in small Cessna's(log book available upon request). APS will at all 

times be on the lookout for public education opportunities and looks forward to working with the FAA 

to safely integrate sUAS into the national airspace system. With our combined experience and strong 

background in flight along with a commitment to safety, APS would make an excellent addition to the 

list of sUAS companies with an exemption and will work hard to form public opinion of sUAS companies 

as professional aviators with the safety of the public number one on their list of priorities. 

II. Training & Operations 

Section 333 of "The Reform Act" states: 

'" ... the Secret my a.[ Transportation shall determine [f certain unmanned aircraft systems may operate 

SC{[ely in the national airspace .system ... In making the determination under subsection (a). the 

Secret my shall determine. at a minimum- (1) which types of unmanned aircraft systems. [f any, as a 

result of their size, weight, speed. operational capability, proximity to airports and populated areas. 

and operation within visual line o.fsight do not create a hazard to users of the national airspace 

.\ystem or the public or pose a threat to national security ... ·· 

APS will utilize the Iris+ air vehicle(s) to conduct operations for the agriculture, aerial photography, 

construction, inspection, surveying and wildlife preservation industries. The Iris+ meets the 

requirements for determination for exemption in the fact it has a maximum weight of 1682 grams, 

maximum speeds of 35 knots and flies for less than seventeen minutes (battery limited). Operating 

within visual line of sight (YLOS) and remaining below 400ft AGL are standard operating 

procedures for APS and will remain so until further advances in safety of flight are introduced to the 

market and regulated by the FAA. As described below, all operations will be confined to those areas 

no closer than one statue mile of any airfield and the proper authorities -.viii be notified with any 

operations within five statue miles. 

The Aircraft: Iris+ UAS 

Design: The Iris+ UAS is built from a variety of durable, lightweight and modular components that 

aid in its capability to be on mission in a variety of conditions. As well, the modularity of 

construction allows for easy exchange of structural, propulsion or sensor components- in the field. 

-As defined by 3DR 

Aircraft Performance/Specifications: 

• Aircraft Composition: polymers/plastic 

• Flight Controls: o Primary: GPS Guided Autopilot (Ground Control Station) 

o Backup: Standard Flight Controls (RC Transmitter) 
··~ 

• Power Supply: Electric Motor /5100 Mah battery pack 

• Speed knots: 35 

• Empty Weight: 1282g 

• Max Payload: 400g/.81bs 

• Launch (Take Off):Gps assisted or manually 

• Recovery (Landing):Gps assisted or manually 

The sUAY System will be operated in the field with both a OIC and a YO in accordance with FAA 

Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following 

Restrictions: 

(a) No flight will be made with a UA Gross weight exceeding 55 pounds; 

(b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an airspeed of 

no more than 25 knots and no further than 3/4 NM from the OIC; 

(c) All operations must utilize a visual observer (YO). The YO and OIC must be able to 

communicate by voice at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of the property 

owner; 

(e) The OIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a 

minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten 

hours logged as a UA pilot with a similar UA type; 

(f) All required pem1its will be obtained from state and local government prior to operation; 

(g) The sUA Y System will not be operated over densely populated areas; 

(h) The sUA Y System will not be operated at air shows; 

(i) The sUA Y System will not be operated over any open-air assembly of people; 

(j) The sUA Y System will not be operated over heavily trafficked roads; 

(k) The sUAY System will not be operated within 5 NM of an airport or heliport without consent 

from appropriate local tower authorities and never within I NM. 

(I) The sUA Y System will not be operated over properties smaller than two acres in size; 

(m) Operations will be restricted to day only and weather conditions equivalent to YFR; 

(n) The OIC will brief the YO and property owner about the operation and risk before the first flight 

at each new location; 

(o) No flight may be made without a Pre-Flight Inspection by the OIC before each operation to 

ascertain that the UA is in a condition safe for flight. 
The OIC and YO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

personnel Qualifications. Additionally, the OIC and YO will perform maintenance on the system and 

will complete a course of maintenance instruction as part oftheir initial training. 

We submit that the combination ofthe UA's light weight, flight performance and ability, fully 

qualified flight crew and strict operation under the guidelines established in 8900.227, and under all 

ofthe Restrictions (a) through (o) listed above, the FAA can have full confidence that the operation 

will have an equivalent or greater level of safety than manned aircraft performing the same mission. 

III. Regulations- Exemption Requested 

Pursuant to 14 C.F.R. § 11.81 (e), APS seeks exemption from the below mentioned regulations and 

provides reason as to why the exemption should be approved based on the level of safety at least 

equal to that of which the rules require. 

• 14 C.F.R. Part 21 Subpart H- Airworthiness Certificates >- Establishes: The procedural 

requiremems for the issuance of airworthiness certificates as required by 14 C. F. R. § 9!.203(a){l) 

Given the small size of the UAS, the limited operating areas and meticulous procedures defined 

within the training and operations section (re-iterated below), an exemption from Part 21 Subpart H 

meets the requirements of an equivalent level of safety under Part II and Section 333 of the "Reform 

Act" with consideration "of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS." 

• sUAS Size: Height I OOmm /Motor to Motor 550mm 

• sUAS Weight: J682g fully loaded 

• sUAS Speed (knots): 35 

• sUAS Capes: 16 minute battery limited flight time (No fuel on board) 

• No operations within one statute mile; Prior notice given to ATC tower/Airport Operator w/in 

five statute miles 

• Minimum distance of250 ft from persons, structures, roads and vehicles not being photographed. 

• Operations will be contained within one square mile and all dangers identified and mitigated 

before the flight plan is finalized into the GPS flight planning program. 

NOTE: The FAA has recent~)' set precedence to this regulation within like given parameters and an exemption 

should be approved on this basis. See exemption approvals for Astraeus Aerial. Aerial MOB, HeliVideo 

Productions. RC Pro Productions. Snapro/1 Media and Pictorvision. 

0 14 C.F.R. § 45.23(b)- Aircraft Marking and Identification Requirements 

> 14 C.F.R. § 45.23(b): Markings ofthe Aircraft: states: 

When marks include on~v the Roman capita/letter "N" and the registration number is displayed on limited. 

restricted or light-sport categ01y aircraft or experimental or provisional~v certificated aircraft, the operator musl 

also display on !lull aircrc!finear each emrance 10 !he cabin, cockpil. or pilot slat ion, in letters no/ less !han 2 

inches nor more than 6 inches high. !he word~ "limi!ed," "reslric!ed," "lighl-spor/, "experimental," or "provisional." 

as applicable. 

APS will ensure compliance with§ 45.29(t) to meet the intent of the regulation by placing the word 

"experimental" on the fuselage of the air vehicle(s). 

NOTE: The FAA has sel precedence 10 !his regula/ion within/ike given paramelers and an exemplion should be 

approved onlhis bwn:~ along wi1h previous exemplions: Nos. 10700, 10167 and I0/67A. Also. see mos/ recem 
exemption approvals for Astraeus Aerial. Aerial MOB, Helil/ideo Productions. RC Pro Productions. Snapro/1 

Media and Pictorvision for further justification of approval. 

• 14 C.F.R. 61.113 (a)(b) and 61.133(a)(l)(ii)- Private and Commercial Pilot Privilege and 

Limitations 

> 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) ofthis section. no person who holds a 

private pilot cert{ficate may act as pilot in command of an aircraft that is canying passengers or property for 

compensation or hire; nor may that person, for compensation or hire. act as pilol in command of an aircraft. (b) A 

priva/e pilot may. for compensation or hire, act as pilot in command of an aircraft in connection with any business 

or employment if: 

> 14 C. F. R. § 61.133: (a) Privileges- (/) General. A person who holds a commercial pilot certificate may ac1 as 

pilot in command of an aircraft- (ii) For compensation or hire. provided the person is qualified in accordance with 

this part and with the applicable parts of this chapter that app()' to the operation. 

Currently, there are no applicable areas identified for sUAS in either the private or commercial sector 

and therefore an exemption is required to conduct commercial operations. As flight operations will 

be conducted in a restricted environment as described in the operations section, these strict guidelines 

will achieve an equivalent level of safety for each individual flight especially when compared to 

commercial flights identified in Part 61 when originally developed. In addition, with the Iris+ 

primary control system utilizing GPS waypoints for guidance and control, APS flight operations will 

be conducted by qualified Iris+ operators with ground school certification and a class Ill medical. 

NOTE: Operators may or may not hold a private pilot license. 

0 14 C.F.R. 91.7(a)- Civil Aircraft Ainvorthiness > States: No person may operale a civil aircraft 

unless il is in an airworlhy condilion. 

Currently there is no airworthiness certificate for the iris+ UAS, however, the manufacturer is in the 

process of obtaining said certificate. In the interim, daily pre and post flight inspections will be 

accomplished in accordance with manufactures maintenance manual(s) and guidance. During flight, 

the OIC will adhere to§ 91.7(b) and abort air operations immediately upon identification of an inflight emergency. Any maintenance performed will be conducted by certified maintenance 

technicians and/or the manufacturer themselves. By applying the prescribed operations, inspection 

and maintenance procedures within the operations section, an equivalent level of safety will be 

achieved. 

NOTE: The FAA has sel precedent by previous(}' issuing exemptions for§ 91. 7(a): Exemption Nos. 8607, 87 3 7, 

8738. 9299. 9299A. 9565. 9565B. /0167. /0/67A, 10602. 32827, and 10700. Also. see most rece/11 exemplion 

approvals for Astraeus Aerial. Aerial MOB, Helil/ideo Productions. RC Pro Productions. Snaproll Media and 

Pictorvision forfuriherjustification of approval. 

• 14 C.F.R. 91.103- Preflight Action> States: Each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight. This information must 

include- (paragraphs a, b, 1 and 2) 

A pre-flight mission brief must be attended by all crew members. This "PMB" will contain weather 

and all flight information including emergency and abort procedures. A signature will be required by 

all crew members indicating they have received the PMB and have read anv NOTAiVIs or other 

procedural updates which may have impact to standard operating procedur~s. In addition, the OIC 
----------------------------------------------~-

will verify air vehicle is ready for flight by coordinating with the maintenance technician during preflight inspection. 

The exemption requested for this section is specifically addressed toward the requirements which do 

not apply to sUAS operations such as runways and air traffic control integration. 

NOTE: As previously stated, air traffic control and airport operator will be notified prior to any operations being 

executed within five statute miles 

NOTE: The FAA has recent(y set precedence to this regulation within like given parameters and an exemption 

should be approved on this basis. See exemption approvals for Astraeus Aerial. Aerial MOB. HeliVideo 

Productions. RC Pro Productions, Snaproll Media and Pictorvision. 

• 14 C.F.R. 91.109(a)- Flight Instruction> States: No personmc~v operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has ful(v functioning dual comrols. 

The majority of sUAS by design are developed with single operational control through the use of 

pre-determined GPS enabled waypoints programmed before or during flight in addition to the use of 

a single hand held transmitter or control station controlled by the OlC. The design does not allow for 

dual controls during flight training and therefore the exemption is requested to qualify/certify 

operators as required by the manufacturer along with specific operations training and procedures 

identified above within section II. 

An equivalent level of safety will be ensured during training operations by utilizing the same flight 

planning process for normal operations. In the flight planning document, all ground hazards will be 

identified and mitigation techniques \viii be enacted to ensure flights stay outside of250 ft of any 

improved roads, vehicles, persons or structures. All training operations will be conducted within a 

confined space on private land in-which permission has been obtained by land owner prior to the 

execution oftraining. 

NOTE: The FAA has set precedent by previously issuing exemptions for§ 91.1 09(a): Exemption Nos. 5778K and 

9862A. Also. see most recent exemption approvals for Astraeus Aerial, Aerial MOB. HeliVideo Productions, RC Pro 

Product ions. Snaproll Media and Pictorvision for further justification of approval. 

• 14 C.F.R. 91.119 (c)- Minimum Safe Altitudes> States: Except whennecessaryfor takeoff or 

landing. no person may operate an aircraft below the following altitudes: (c) Over other than congested areas. An 

altitude of 500 feet above the swface, except over open water or sparse(v populated areas. In those cases. the 

aircraft mc~v not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

All APS operations will be conducted at 400ft AGL or below in uncontrolled Class G and 

occasionally E airspace. As sUAS are inherently safer than traditional aircraft due to their small size, 

light weight, battery operated vice fuel and no human on-board; APS will not operate within 250ft to 

any improved roads, vehicles persons or structures (other than those being inspected as part of the 

flight operation). In addition, objects/hazards will be identified and geo-located prior to flight to be 

utilized within the flight planning stages to ensure this objective is met. 

• 14 C. F. R. 91.121 - Altimeter Settings > States: Each person operating an aircraft shall maintain the 

em ising altitude orjlight level of that aircraft, as the case may be. by reference to an altimeter that is set. when 

apercu ing ... 
sUAS are equipped with Global Positioning System (GPS) which provide altitude and geo-location 

data to the operator vice utilizing an altimeter. Due to this fact, an exemption is required for this 

system to be utilized in flight. GPS are precise within a few feet and therefore meet a safety level 

equal to if not higher than regulatory guidance. 

As described in the emergency procedures section; in the event the air vehicle losses GPS signal, 

automated landing will immediately commence. The flight plan is built in such a way that hazards 

are identified prior to launch and an immediate landing within the flight plan will ensure all hazards 

are avoided. 

NOTE: The FAA has recent(v set precedence to I his regulation within like given parameters and an exemption 

should be approved on this basis. See exemption approvals for Astraeus Aerial. AeriaiJ'viOB, HeliVideo 

Productions, RC Pro Productions, Snapro/1 Media and Pic1orvision. 

• 14 C.F.R. 91.151(a)- Fuel Requirements for Flight in VFR Conditions> States: No person may 

begin ajlighl in an airplane under VFR condilions unless (considering wind andforecasl weal her condilions) /here 

is enoughfuellojly 10 lhefirsl point ofinlended landing and. assuming normal cruising speed- (I) During lhe day. 

10 Rv after I hell for a/leas/ 30 minules: 

This regulation is written based on the capabilities of a traditional aircraft which have flight times of 

several hours or greater; therefore, with the majority of sUAS which have flight times of only an 

hour or less, this regulation would effectively deny the ability of the air vehicle to operate. 

Using a Cessna 182 as an example, approximately 8% remaining fuel is required to meet the 30 

minute flight time directed by this regulation. To meet the intent, APS, will operate its air vehicles to 

no less than I 0% remaining battery power to ensure safe landing and retrieval of the air vehicle. This 

I 0% buffer is greater than the Cessna 182 and the ability to quickly and safely land sUAS in nontraditional environments ensures at least an equal level of safety. 

NOTE: The FAA has set precede/11 by previously issuing exemp1ions for§ 91.151 (a): Exemption Nos. I 067 3. 2689F, 

5 745. I 067 3 and I 0808. Also, see most rece/11 exemption approvals for Astraeus Aerial. Aerial MOB. HeliVideo 

Productions. RC Pro Productions. Snapro/1 Media and Pic10rvision forfurtherjuslification of approval. 

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b)- Maintenance Inspections 

> 91.405(a) States: Each owner or operator of an aircraft-(a} Shall have I hell aircraft inspec1ed as prescribed in 

subpart E of this pari and shall between required inspections. except as provided in paragraph (c) oflhis section. 

have discrepancies repaired as prescribed in part 43 of I his chapler 

> 91.407(a)(l) States: (a) No person may operme any aircraft 1hm has undergone maimenance, prevemive 

maimenance. rebuilding. or alteration unless-( I) It has been approved for return to service by a person authorized 

under§ 43.7 of this chapter 

> 91.409(a)(2) States: (a) Except as provided in paragraph (c) oflhis sec/ion. no person may operate an aircraft 

unless, within 1he preceding 12 calendar mo111hs. it has had-(2) An inspection for the issuance of an airworthiness 

cen{ficme in accordance with part 21 of this chapler. No inspection pe1jormed under paragraph (b) of this section 

mc~v be suhstilutedfor any inspection required by this paragraph unless it is pe1jormed by a person authorized 10 

pe1jorm annual inspections and is e111ered as an '·annual·' inspeelion in the required maintenance record~. 

> 91.417(a) & (b) States: (a) Ercept for work pe1jormed in accordance with§§ 91.411 and 91.413. each 

regislered owner or operator shall keep the following records for the periods specified in paragraph (h) of this 
------------------------------------au. 

section: (paragraphs I (i- iii). 2 (i- vi)); (b) The owner or operator shalf retain the following records for the 

periods prescribed: (paragraphs I - 3) 

Due to the fact the Iris+ UAS at present does not have an airworthiness certificate, these regulations 

do not apply and therefore an exemption is required. Pre/Post and routine inspections (not to exceed 

50 flight hours) and maintenance will be conducted in accordance with the manufacturer's guidance 

as stated in the operations manual. In addition, to meet the intent of these regulations, APS, will 

maintain daily logs of pre and post flight inspections and have maintenance performed by certified 

technicians and/or the manufacturer themselves. In the event maintenance is required, certified 

technicians will verify the air vehicle is in flight readiness status prior to releasing to OIC for use in 

operations. 

Unscheduled maintenance will be accomplished in the event of a mechanical or structural failure 

during flight. Upon completion of unscheduled maintenance, documentation will be provided to the 

Director of Operations to sign off and verify that the air vehicle is once again ready for flight and 

accept the level of risk associated with returning the air vehicle to flight status. At no time will there 

be changes made to the air vehicle which would impact the structural integrity of the air frame 

without the manufacturer making such changes and verifying the flight its air worthiness. 

All inspection and maintenance will be documented and maintained in-house. These actions will 

meet the intent of the regulation exemption is being requested and lead to the equivalent level of 

safety. 

NOTE: The FAA has recenlly set precedence to this regulation within like given parameters and an exemption 

should be approved on this basis. See exemption approvals for Astraeus Aerial. Aerial MOB, HeliVideo 

Productions. RC Pro Productions. Snapro/1 Media and Pictorvision. 

IV. Public Interest 

The public's best interest is achieved by the safe integration of UAS into the NAS. With the ongoing 

exemption process, the FAA has to identify those exemption requests with the public's best interest 

in mind and select the companies who will be able to achieve this in a safe and responsible manner. 

Two of the main problems the public has with UAS are the fear of what they will be used for and 

whether or not they are safe to fly within the same airspace as commercial airliners. APS is more 

than willing to help with public education and that starts with conducting operations within strict 

operating environments and then providing the results to the public to start to sway opinion in a 

positive light. 

APS will provide any additional information requested and will diligently work with the FAA to 

make this approval a reality as it is in the best interest and safety ofthe public as directed by 

Congress 

V. Privacy Concerns 

As previously stated, one of the main concerns the public has with the integration of UAS into the 

NAS is privacy and spying; especially as of recent with the "disclosure" of the NSA's 

communication programs. The media has also placed a negative light on UAS when it comes to 

privacy; showing only how the military has used this technology to conduct combat operations 

through the use of the visual and infrared sensors they carry. 

The most efficient and successful avenue to combat these concerns is to educate the public in how 

UAS technology will be used to exponentially improve all of our lives as Americans and place 

e1~1phasize on how we should embrace the technology instead of fearing it. In these regards, APS, 

wtlllook at actions we can take to move forward with this endeavor and assist the FAA and all UAS 

' 
employment companies as a whole to better public percepti9n and create a cohesive environment we 

all can operate in safely. 

VI. FAA Collaboration 

APS is committed to the safe integration of UAS into the NAS and will provide any and all 

information on its flight operations to the FAA to assist in the rules making process. As stated in the 

operations section, post flight logs will be required to be completed to produce monthly flight 

summaries which will include both positive and negative reporting placing emphasize on any issues 

which may arise during any segment of the operations. APS offers the monthly summaries to the 

FAA as input and flight data to ensure accurate information is utilized along with offering our 

expertise and knowledge in the rule making process. 

Summary~ Federal Register 

Pursuant to Section 333 of PL I 12-95 commonly known as the "FAA Modernization and Reform Act 

of2012" or "The Reform Act", Aerial Photography and Survey lie. (d/b/a APS), hereby applies for 

authorization to conduct commercial unmanned aerial syste.ms (UAS) operations for the agriculture, 

aerial photography, construction, inspection, surveying, and wildlife preservation industries, within 

the State of Oregon ; within Class G and occasionally E airspace. 

Rules in which APS seeks exemption: 

• 14 C.F.R. Part 21 Subpart H 

• 14 C.F.R. § 91.7(a) 

• 14 C.F.R. § 45.23(b) 

• 14 C.F.R. § 61.113 and 61.133(a)(l)(ii) 

• 14 C.F.R. § 91.7(a) 

• 14 C.F.R. § 91.103 

• 14 C.F.R. § 91.1 09(a) 

• 14 C.F.R. § 91.119 

• 14 C.F.R. § 91.121 

• 14 C.F.R. § 91.151(a) 

• 14 C.F.R. § 91.405(a) 

• 14 C.F.R. § 91.407(a)(l) 

• 14 C.F.R. § 91.409(a)(2) 

• 14 C.F.R. § 91.417(a) & (b) 

Throughout this exemption request, APS has shown how their expertise and knowledge with UAS 

technology will ensure the public's best interest is at hand and assist the FAA with their charge to: 

" ... safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system ... " as directed by Congress. They have also shown how the approval of this request will meet 

and exceed " ... at least an equivalent level of safety ... " for the regulations they seek exemption. 

At each level through process refinement, APS, will capture and document the best practices to 

develop proven tactics, techniques and procedures and provide that information to the FAA to 

incorporate into the UAS integration process.